Thank you for participating in our webinar on mandatory reporting in Germany! Here you will find an overview of the most important questions and answers that were asked during the event. Our aim is to give you a clear insight into the upcoming requirements and practical solutions.
The transfer of the TSE serial number has been implemented - if a TSE is linked to the EFR, the serial number is transferred to the creation of the mandatory reporting XML file.
We have successfully completed ISO 27001 certification - the certificate will be available in April 2025 and published accordingly.
This is included free of charge in the manual reporting service and is already available in the efsta portal. In the automatic fee-based reporting service, it is part of the service fee.
Here is our recommendation: If the replacement cash register is linked to an EFR, you will automatically receive an e-mail on Mondays that a new cash register is in use at a business premises. You must define whether the cash register to be replaced is being replaced and is no longer in your possession: If so, the defective cash register must be reported with a decommissioning message. If the temporarily defective cash register is repaired and is used again, it has not been taken out of service - but the replacement cash register must then be deregistered.
I assume you mean that MSPOS has been stored as an Elster contact in the efsta portal - then you will receive all change notifications from all your taxable customers. If this is not desired, you must adjust this in the efsta portal.
In principle, 3 different types of information must be maintained:
Details of the taxable person. This must be maintained once per company. You can maintain this directly for the company in the properties under the "Elster report" tab or on an organization via CSV import. Please note that the "German tax number" with 13 digits must be entered for the tax number and not the VAT ID with DE...
Location data: Name and address of the location
Cash register data (serial number, software, manufacturer, model). Here you can download a CSV export in the "Portal export" menu with the type "Elster data check".
This question can only be answered once Elster has published the documentation on mass reporting - announced for May 2025.
Elster is due to publish documentation in May 2025. We need to review this and adapt our mandatory reporting solution accordingly.
The BMF has described this in the FAQs: https://www.bundesfinanzministerium.de/#collapse170442-3-4 : 5. Do electronic recording systems that are not currently in use but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with Section 146a (4) AO?
If electronic recording systems are purchased by the taxpayer in order to record business transactions or other transactions that must be recorded, these electronic recording systems must also be reported at the time of purchase, even if their use is not planned until a later date. If no certified technical security device has yet been assigned to these electronic recording systems, it is sufficient for only the electronic recording system to be reported.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. cash register dealers or legally independent group companies), these electronic recording systems are not subject to notification.
The feedback from the efsta portal relates to missing data for a complete Elster declaration. The quality of the master data - e.g. whether the address has been entered correctly - is not checked.
Currently no.
The download link does not change. You can still download the data at a later date. All notifications can be seen in the portal under "Fiscal notifications".
Cash registers without a TSE can be reported via the efsta reporting service in compliance with the law. The reference to complete data indicates MANDATORY fields of the reporting obligation, such as the mandatory entry of the tax number.
Yes, please contact your efsta partner manager.
Only "open TSE messages" are sent by e-mail. As soon as the messages have been created (downloaded), they are no longer sent by e-mail.
Here is the BMF's definition in its FAQs: 5. Do electronic recording systems that are not currently in use but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with Section 146a (4) AO?
If electronic recording systems are purchased by the taxpayer in order to record business transactions or other transactions that must be recorded, these electronic recording systems must also be reported at the time of purchase, even if their use is not planned until a later date. If no certified technical security device has yet been assigned to these electronic recording systems, it is sufficient for only the electronic recording system to be reported.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. cash register dealers or legally independent group companies), these electronic recording systems are not subject to notification.
Reference is also made to §854 BGB: German Civil Code (BGB)
§ Section 854 Acquisition of possession
(1) Possession of an object is acquired by obtaining actual control over the object.
(2) The agreement of the previous owner and the acquirer is sufficient for acquisition if the acquirer is in a position to exercise control over the property.
Here is the BMF's definition in its FAQs: 5. Do electronic recording systems that are not currently in use but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with Section 146a (4) AO?
If electronic recording systems are purchased by the taxpayer in order to record business transactions or other transactions that must be recorded, these electronic recording systems must also be reported at the time of purchase, even if their use is not planned until a later date. If no certified technical security device has yet been assigned to these electronic recording systems, it is sufficient for only the electronic recording system to be reported.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. cash register dealers or legally independent group companies), these electronic recording systems are not subject to notification.
Reference is also made to §854 BGB: German Civil Code (BGB)
§ Section 854 Acquisition of possession
(1) Possession of an object is acquired by obtaining actual control over the object.
(2) The agreement of the previous owner and the acquirer is sufficient for acquisition if the acquirer is in a position to exercise control over the property.
Here is the BMF's definition in its FAQs: 5. Do electronic recording systems that are not currently in use but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with Section 146a (4) AO?
If electronic recording systems are purchased by the taxpayer in order to record business transactions or other transactions that must be recorded, these electronic recording systems must also be reported at the time of purchase, even if their use is not planned until a later date. If no certified technical security device has yet been assigned to these electronic recording systems, it is sufficient for only the electronic recording system to be reported.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. cash register dealers or legally independent group companies), these electronic recording systems are not subject to notification.
Reference is also made to §854 BGB: German Civil Code (BGB)
§ Section 854 Acquisition of possession
(1) Possession of an object is acquired by obtaining actual control over the object.
(2) The agreement of the previous owner and the acquirer is sufficient for acquisition if the acquirer is in a position to exercise control over the property.
An e-mail address must be stored in the efsta portal for each business site/location in order to make use of the weekly efsta mail service.
The cash register serial number is explained as follows in the BMF's filling aid: This is the serial number as defined in Section 6 No. 6 KassenSichV for cash registers. In the case of taximeters and odometers, you will usually find this on the device, often on the invoice or on the till receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to points 1.16.2.5 and 2.2.3.1 of the AEAO on Section 146a AO and Chapter 9.3.1 of the Technical Guideline BSI TR-03153-1
In the event of a cash register inspection, an auditable scenario should be recorded in MeinELSTER.
Recording a SW client serial number seems advisable to me here.
Data transfer, such as the TSE serial number, is not possible due to the lack of data transfer to the efsta portal.
Correct.
The cash register serial number is explained as follows in the BMF's filling aid: This is the serial number as defined in Section 6 No. 6 KassenSichV for cash registers. In the case of taximeters and odometers, you will usually find this on the device, often on the invoice or on the till receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to points 1.16.2.5 and 2.2.3.1 of the AEAO on Section 146a AO and Chapter 9.3.1 of the Technical Guideline BSI TR-03153-1
In the event of a cash register inspection, an auditable scenario should be recorded in MeinELSTER.
The cash register serial number is explained as follows in the BMF's filling aid: This is the serial number as defined in Section 6 No. 6 KassenSichV for cash registers. In the case of taximeters and odometers, you will usually find this on the device, often on the invoice or on the till receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to points 1.16.2.5 and 2.2.3.1 of the AEAO on Section 146a AO and Chapter 9.3.1 of the Technical Guideline BSI TR-03153-1
In the event of a cash register inspection, an auditable scenario should be recorded in MeinELSTER.
The cash register serial number is explained as follows in the BMF's filling aid: This is the serial number as defined in Section 6 No. 6 KassenSichV for cash registers. In the case of taximeters and odometers, you will usually find this on the device, often on the invoice or on the till receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to points 1.16.2.5 and 2.2.3.1 of the AEAO on Section 146a AO and Chapter 9.3.1 of the Technical Guideline BSI TR-03153-1
In the event of a cash register inspection, an auditable scenario should be recorded in MeinELSTER.
The Simulator TSE is filtered out from 14.04.2025 and now shows all TSE fields as empty, so cash registers with Simulator TSE can be reported as if they had no TSE.
No.
The reporting obligation requires a report relating to business premises.
The obligation to register cash registers is intended for business premises in Germany.
Yes, you will receive the recording with our summary by e-mail.
An implementation of the efsta EFR with data exchange with the efsta portal is the technical basis for being able to use our reporting service. If you would like to report other cash register systems used in a business premises in addition to cash register reports already recorded in this way, you can add them manually to an existing report.
No.
The EFR must be deactivated. In the report, the historically recorded cash balance is reported using the required gross method.
Yes, the Fiscalization Act states that if you use an electronic recording system, it must comply with the Cash Register Security Ordinance and the cash registers must be connected to a TSE.
The transitional period for the mandatory reporting of cash registers in Germany stipulates that the status of the cash register systems, including the TSEs, must be recorded at the time of reporting. All changes prior to this date do not have to be reported.
The transitional period for the mandatory reporting of cash registers in Germany stipulates that the status of the cash register systems, including the TSEs, must be recorded at the time of reporting. All changes prior to this date do not have to be reported.
Cash register dealers do not have to enter cash registers intended for sale to taxable persons in MeinElster. If a taxable person has cash registers in stock that are not yet in productive use, these must be reported - the possession of a cash register system must already be reported.
Yes - the auditors justify this on the one hand with the fact that the cash register is in the possession of the taxpayer and also a test document could be available to the auditor, which he will then also check: is the test cash register registered yes/no.
By default, the e-mail address in the Elster contact is empty. E-mails are only sent to the taxpayer once an e-mail address has been entered as an Elster contact.
Please note that when using an efsta offline EFR version, the legally required data is NOT transmitted to the efsta portal and is therefore not available for data export to fulfill the reporting obligation.
E-mails are sent to the Elster contact as soon as an e-mail address has been entered, i.e. also to those taxpayers who do not yet have all the required information.
You can download an XML file per location at any time via an export function in the efsta portal for transmission to MeinElster - independently of the weekly e-mails.
What is meant here? The customer can download the XML via the portal (logged in or with a link by e-mail). The portal API can also be used. However, this is only possible for partners (not end customers).
According to the current state of knowledge, one XML file per branch / operating site is planned - we are not aware of a summary of X operating sites in one file.
efsta is still implementing this for customers with 5+ locations.
The options for transferring data to the BMF are the responsibility of the BMF - we have no information about a planned change to the MeinElster portal for the purpose of cash register reporting. Please contact the BMF or BSI with this question.
Is there an example? As we understand it, the tax number only exists for each company.
As we believe that this leaves room for interpretation in the BMF's rules, we recommend consulting a tax advisor.
Yes - primarily intended for systems that are a test system or are kept in stock, for example, as a reserve.
Is not planned.
Each XML file per business premises is prepared in a so-called gross method: every cash register/ TSE etc. that has ever been logged on/off at this business premises is included in the XML file. This means that the auditor can always access the entire history in the event of an audit.
No
As offline EFRs do not communicate with the efsta portal, it is currently not possible to export data from the portal. Please switch to an online EFR if possible. An export of the serial number of the TSE is currently not on our development roadmap.
We cannot make any binding legal recommendations here as, as mentioned in the webinar, a certain amount of room for interpretation is possible. Please ask a tax advisor how this should be implemented.
The regulations require several data fields such as the software of the cash register or the serial number of the system used. Please read the complete guidance from the BMF.
If you submit all requested data via our efsta EFR API - yes - but you need to add a contact email address for a responsible person of your taxable client. It is also possible to add the data of the taxable person via the portal API (available via docs.efsta.net).
Deadlines:
From 01.01.2025, all electronic cash register systems and cash registers used in companies must be reported to the responsible tax office. Existing cash registers must be reported to the tax office by 31.07.2025 at the latest (late reporting deadline).
For new systems (purchase from July 1, 2025): Notification within one month of purchase. For decommissioning: From July 1, 2025, a report must also be submitted if a recording system is decommissioned; prior to this, the purchase report may have to be submitted later.
We are considering offering this service in the future - the decision will be made at the end of the first quarter of 2025.
Not yet planned.
All changes made in one of your branches that must be reported via MeinElster for cash register reporting obligations must be made within 30 days.
Other POS systems that are not recorded in efsta can be added manually in MeinElster - see the BMF's completion aid.
If new serial number, software, hardware or TSE, a message must be issued
The TSE serial number is automatically recognized by the EFR and sent to the efsta Cloud. The customer must enter the serial number of the cash register themselves in the portal under FiscalRegister when clicking on the cloud or alternatively enter it in the EFR.
The reporting obligation provides for electronic recording systems in Germany to be recorded by the taxable company. Since the test system in your example is not operated in Germany and an auditor may find a test document, we understand that this test system does not have to be reported.
There is always one XML file per location/operating site. It is not possible to report several locations with one file.
After the initial entry of the reportable data, all reportable changes, such as an exchange of cash registers (deregistration/registration), a change of TSE, etc., must be entered in My Elster within one month in accordance with §146a.
This is up to you to decide which data maintenance work you can and want to take on as a cash register manufacturer - as well as whether you want to offer this as a (chargeable?) service for your customers.
If there are relevant changes, an automated e-mail is sent to the ELSTER contact on file with a link that can be used to request and download the XML. It is not necessary for the entrepreneur to log in.
Example XML available from 01.12.2024
Has been defined in the interface since the introduction of the Cash Register Security Ordinance. In DSFinV-K, however, this data is optional except for the serial number.
Recording, questions and deck will be provided collectively.
Only German companies are included.
Each cash register is given its own serial number, which is usually located on the device itself. It is best to have a number that is printed on the cash register device so that an auditor can check this.
The XML file can be customized in the efsta portal before it is created and downloaded by the entrepreneur.
We interpret the reporting obligation to mean that updates are not subject to reporting - but major software updates or software extensions are. For a legally binding assessment, please contact a tax consultant.
If you only enter data MANUALLY in MeinElster - i.e. data such as the cash register serial number, cash register type, etc. - this data is not transferred to the efsta portal and is therefore not automatically available as an XML file download for change notifications, for example. If this recording of reportable data in the efsta portal is not important to you and you are aware that unrecorded data will not be available in the XML reporting file, the recording of terminal data should be seen as optional.
The KOMet-AG stands for: Consensus Working Group on Notification Procedures for Electronic Recording Systems. There is a weekly online meeting where questions about the reporting obligation are discussed. The KOMet-AG is NOT responsible for the content of the legal basis of a KassensichV - this is the BMF.
The Komet-AG is expressly not the nationwide information center for all questions concerning § 146a (4) AO!
The assistance offered only applies to eAs software developers.
The aim is to successfully introduce the Komet message via the ERiC interface.
End customers cannot address any questions to KOMet-AG.
POSDeactivationDate is of course empty for an active cash register. If a cash register is not yet active, POSActivationDate is empty. The TSE fields are also empty for cash registers that are not yet active or deactivated, as there is no longer a TSE attached to the cash register. All other fields should be filled.
The specified e-mail addresses are sent a link in the event of relevant changes where the data can be checked and edited again, and an XML of the current data can be requested and downloaded.
1. yes, the export exists to recognize unentered or incorrectly entered data before the message is created
2. the software version is not relevant for the message and only exists as an optional field
3. the manufacturer of the cash register should be stated under Manufacturer
4. no, no new EFR version is required for the TSE report. All required data has already been recorded in the EFR since the beginning of the Cash Register Security Ordinance for the DSFinV-K and sent to the efsta Cloud.
Each operating city/location must be reported separately.
We interpret that computers that are not specially set up for cash register transactions and do not use cash register software to record business transactions are not subject to the reporting obligation - from the moment the computer uses a cash register client, it must be reported. The computer owned by the taxpayer becomes a cash register from the moment the client is installed - even without a TSE. Please note that this is an interpretation of efsta and is not legally binding - for this purpose we must refer you to a tax advisor.
The number of electronic recording systems must be reported within one month for each operating city in the event of changes.
Special characters are taken into account in the export
We interpret a sub-supplier as having cash registers in stock for the purpose of selling to taxable end customers - this is to be regarded as current assets and therefore not reportable. The taxable end customer who buys a cash register has this as a fixed asset and must already report possession of the cash register. Please note that this is an interpretation of efsta and is not legally binding - for this purpose we must refer you to a tax advisor.
Correct
How do we interpret POS input devices? If input devices, such as tablets, smart phones or other operating devices, are integrated directly into the POS system and are used to enter checkout transactions, they are considered part of the POS system. In this case, they are covered by the reporting obligation as they contribute to the collection and storage of data. Please note that this is an interpretation of efsta and is not legally binding - for this purpose we must refer you to a tax advisor.
Thank you for this important question. We currently create ONE XML report file per location / POS system in the portal export logic. We will check this point in our development to see how we can implement this if necessary.
Please contact our support team: Use our ticket system, which you can reach via ticket@efsta.eu.
The first report on cash registers must be submitted from January 1, 2025 with a six-month transitional period until June 30, 2025 - with a one-month extension for reporting new cash registers, the report must be submitted by July 31, 2025 at the latest. After the first report, you only have to report changes (decommissioning of cash registers or TSEs or new cash registers, etc.) and new branches.
Bei Neuinstallationen sowie bei bestehenden Installationen von Registrierkassen muss im efsta-Portal vermerkt und überprüft werden, ob der Wert >>interne Filial-ID („Int. FILIAL ID“)<< im Portal mit dem TL (Terminal Location) (siehe DE-Leitfaden 5.2.) im efsta EFR übereinstimmt.
Minor software updates do not need to be recorded - the authorities want to be informed about major software release updates if major functions or the architecture change.
This is not yet planned. The obligations of the data transmitter to verify the identity of the taxable company are complex and we will inform you if efsta offers this service.
As far as we know, the tax authorities do not inform taxable customers for this reason.
The first reporting of cash registers must take place from January 1, 2025, with a transitional period of 6 months until June 30, 2025 - with one month added to report new cash registers. The notification must be made by July 31, 2025 at the latest.
Sent by e-mail together with a summary.
Sent by e-mail together with a summary.
As long as the taxable customer uses a valid TSE certified by the BSI, they are free to choose which TSE (USB, SD card, cloud) from which provider they wish to use. If they change a TSE, this must be recorded in the process documentation and is also relevant for the reporting obligation - the new TSE serial number must be reported.
The taxable customer has until the end of June (plus one month) to complete the registration of the cash registers.
The addition or merging of reporting data from different POS systems must be carried out manually by the taxpayer in the MeinElster portal.
For sales inquiries, please use our ticket system, which you can reach at sales@efsta.eu.